Capital Confirmation Inc. PRIVACY STATEMENT

Effective on: July 1, 2004

Capital Confirmation, Inc. is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.confirmation.com. Because this Web site wants to demonstrate its commitment to our users' privacy, it has agreed to disclose its information practices. 

1. What personally identifiable information Capital Confirmation Inc. collects.
2. What personally identifiable information third parties collect through the Web site.
3. What organization collects the information.
4. How Capital Confirmation Inc. uses the information.
5. With whom Capital Confirmation Inc. may share user information.
6. What choices are available to users regarding collection, use and distribution of the information.
7. What types of security procedures are in place to protect the loss, misuse or alteration of information under Capital Confirmation Inc.'s control.
8. How users can correct any inaccuracies in the information.

If users have questions or concerns regarding this statement, they should first contact Brian Fox, or Chris Schellhorn by telephone at: (615) 844-6222, or by e-mail at: Customer.Support@confirmation.com. If users do not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process. (http://www.truste.org/consumers/watchdog_complaint.php) TRUSTe will serve as a liaison with the Web site to resolve users concerns.

Information Collection and Use

Information Collection

Capital Confirmation Inc. is the sole owner of the information collected on Confirmation.com. Capital Confirmation Inc. collects information from our users at several different points on our Web site.

Registration

In order to use this Web site, a user must first complete the registration form. During registration a user is required to give professional and personal contact information (such as name and email address). We use this information to validate our users, and to therefore grant access to our service. We also ask our accounting customers to provide their CPA registration/credentialing information in order to validate his/her status to include employment verification.

Order

We request information from the user on our order form. A user must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer's orders. If we have trouble processing an order, the information is used to contact the user.

Third party information is collected on the site (such as client information entered for the purpose of conducting confirmations of accounts) The following are the types of information that are requested for a client: contact information, client's name, client contact name, client address, client contact's email address. This information is used to validate the client users of the service. A welcome email is generated to the clients to notify them that they have been set up on the service by their accountant and to provide them notification of their initial security codes. These emails are only used for the primary purpose of providing the service of the site and are not used for any secondary purposes.

Information Use

Capital Confirmation Inc., through its on-line service production site, Confirmation.com, collects two types of information:

1. Demographic Information
2. Customer Financial Information

Demographic Information is stored on our system. While in use, the information is used to validate the user, and to determine access permissions. The customer is free to modify this information at any time.

Customer Financial Information includes certain bank balance information that is stored in our database on a temporary basis, and credit card payment information provided by the customer at the time of the payment for the provision of services.

Confirmation.com is an on-line provider of balance assurance services for its customers. The first product offering now available is the on-line confirmation of banking account balances. This service is designed for use by accountants in their conduct of audit procedures as described by generally accepted accounting principles (GAAP).

Profile

We store information specifically given to us by our users through the account set up process, and or the account edit process. In addition, we store IP Address, browser type, Internet service provider (ISP) and access times. We do not store information provided through the use of cookies. A profile is stored information that provides the company with information describing the end user of our service. All such collected information is used only for the conduct of the provision of our service.

Cookies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use session ID cookies. We use session cookies to make it easier for you to navigate our site. We set a session ID cookie that holds an authentication ID. A session ID cookie expires when you close you browser. We do not use persistent cookies.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

Third Party Advertising

Confirmation.com does not display or solicit any third party advertising at any time.

Log Files

Like most standard Web site servers we use log files. This includes Internet protocol (IP) addresses, browser type and Internet service provider (ISP) and access time. Capital Confirmation Inc. and its production site, Confirmation.com uses log files only to track errors in the system. Log file information is not tied to a user's personally identifiable information.

Clear Gifs (Web Beacons/Web Bugs) Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. Confirmation.com does not use Clear Gifs in the provision of its service offering.

Communications from the Site

Updates

We send all new members a welcome email. We will from time to time send email notification, mail or call you to provide you with information concerning updates or enhancements to our service. The communications are not promotional in nature as they are strictly related to the use of our service.

Customer Service
We communicate with users on a regular basis to provide requested services, and in regard to issues relating to their account we reply via email or phone in accordance with the user's wishes.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Sharing

Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site.

Aggregate Information (non-personally identifiable)

We do not share aggregated demographic information with our partners and advertisers.

These are the instances in which we will share users' personal information:

Third Party Intermediaries

We use an outside credit card processing company, Verisign®, to bill users for services. This company does not retain, share, store or use personally identifiable information for any secondary purposes.

Business Transitions

In the event Capital Confirmation Inc. goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users' personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users' personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.

Security

This Web site takes every precaution to protect our users' information. When users submit sensitive information via the Web site, their information is protected both online and off-line.

The entire Confirmation.com site is encrypted and is protected with the best encryption software in the industry - 128-bit SSL. This means that when our registration/order form asks users to enter sensitive information (such as credit card number), that information is encrypted using the best encryption software in the industry - 128-bit SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'.

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every quarter as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users' information is protected. Finally, the servers that store personally identifiable information are in a secure environment, in a hardened hosting facility.

If users have any questions about the security at our Web site, users can send an email to: Customer.Support@confirmation.com.

Supplementation of Information

In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources.

ID, Credentialing Verification

We use outside sources to verify a user's accounting credentials to validate that users access to our system.

Correcting/Updating/Deleting/Deactivating Personal Information

If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users' personally identifiable information. This can be done on the edit profile tab or by emailing our Customer Support at Customer.Support@confirmation.com.

Notification of Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the site through deactivating their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact us at:

Phone: (615) 844-6222
Fax: (615) 376-7971
Email: Customer.Support@confirmation.com

Postal Address 214 Centerview Drive
Brentwood, Tennessee - 37027